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Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 7 of 13 D. This Court Should Order Production of Documents Responsive to Requests No 17 and 18. Requests Nos. 17 and 18 seek documents “concerning any statement made by You or on Your behalf to the press or any other group or individual, including draft statements, concerning Ms. Giuffre, by You, Ross Gow, or any other individual, from 2005 to the present, including the dates of any publications, and if published online, the Uniform Resource Identifier (URL) address” and “all documents concerning which individuals or entities You or Your agents distributed or sent any statements concerning Ms. Giuffre referenced in Request No. 17 made by You or on Your behalf.” In other words, Ms. Giuffre is seeking what statements about Ms. Giuffre Defendant distributed and to whom. This is another basic request, particularly in a defamation case. Moreover, the only person who knows the full extent of Defendant’s defamation of Ms. Giuffre is Defendant. In her brief, Defendant states that “the defense previously produced responsive documents.” It is likely that Defendant is referring to the press release email communication from Mr. Gow to various media outlets. The defamatory statements contained therein are referenced in Ms. Giuffre’s Complaint. Since filing the instant motion, Ms. Giuffre has become aware that Defendant caused additional defamatory statements to be published. This is important. Ms. Giuffre has discovered an article that refers to a different defamatory statement, not contained in the above-state press release. See McCawley Dec. at Exhibit 2, January 8, 2015, The Sun (online) article: “Prince 99 Andrew’s pal Ghislaine ‘groped teen girls,”” (Miss Maxwell’s spokesman branded the accusations against her a “web of lies and deceit” — adding: “None of these allegations are on oath. “These girls are saying anything they want for money.”). Communications bearing this language are responsive to these requests, as is the publication in which Ms. Giuffre discovered